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IRS/SJSU Small Business Tax Institute

Mid-Year Tax Update June 22, 2017

Professor Annette Nellen, CPA, CGMA, Esq.MST ProgramSan José State Universityhttp://www.sjsu.edu/people/annette.nellen/http://www.21stcenturytaxation.com

Professor Joel Busch, CPA, Esq.MST ProgramSan José State University

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Agenda

Individuals Businesses Health Care Property Transactions Practice & Procedure Miscellaneous California Updates

Individuals VW Settlement CWA – Need It and More For Airplane Donation Need Proof of Cash Contributions

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VW Settlement For VW’s diesel emission problems Various arrangements including car

buyback Likely also receive “additional

restitution payment.” Watch for details from VW, possible

guidance from IRS and state Review nature of the transaction

and reason for the payment Reconcile any 1099 rec’d to be sure

what’s taxable and what might not be

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CWA – Need It and More For Airplane Donation

Izen, 148 TC No. 5 (3/1/17) Court disallowed $338K deduction for donation of

interest in 40-year old airplane §170(f)(12) not followed

CWA not attached to return 1098-C not filed

5http://www.ustaxcourt.gov/UstcInOp/OpinionViewer.aspx?ID=11131

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Need Proof of Cash Contributions

Wainwright, TC Memo. 2017-70 (4/25/17) 2010, IRS disallowed charitable contributions of

$9,450 Court agreed Any cash donation

NEED documentation of some sort If $250 or more, need CWA W produced none for the court

http://www.ustaxcourt.gov/ustcinop/opinionviewer.aspx?ID=11190

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Businesses

Mileage Rates Research Credit / Payroll Credit Guidance PLLC Attorneys Subject to SE Tax

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Mileage Rates for 2017Notice 2016-79 (12/13/16)Business - 53.5¢/mile [down from 54¢] 25¢ represents depreciation

Medical and Moving - 17¢/mile [down from 19¢]

Charitable - 14 ¢/mile [fixed by statute]Must follow Rev Proc. 2010-51

https://www.irs.gov/pub/irs-drop/n-16-79.pdf9

Research Credit / Payroll Credit Guidance Notice 2017-23

Interim guidance Basics, definitions, examples Comments requested by 7/17/17 Special amended return option

If file return for tyba 2015 and don’t elect to claim research credit as payroll credit, can amend that return by 12/31/17 to do so. “FILED PURSUANT TO NOTICE 2017-33” at top of Form

6765https://www.irs.gov/pub/irs-drop/n-17-23.pdf

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PLLC Attorneys Subject to SE Tax

Castigliola, TC Memo 2017-62 (4/12/17) 3 attorneys were member-managers of professional

LLC in Mississippi Per CPA advice, only paid SE tax on their GP which

were in line with legal salaries in the area. Did not pay SE tax on their distributions beyond GP.

Rationale of CPA – are “limited partners” per §1402(a)(13). Court – NO!

Applied Renkemeyer (TC 2011)

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PLLC Owners ≠ Limited Partners

§1402(a)(13) enacted in 1977 No definition of “limited partner” in Code or regs

So, use “ordinary meaning” in 1977 1977 – few states allowed LLCs

Does person claiming exemption have position that is “functionally equivalent to that of a limited partner in a limited partnership” per state law? Here, owners had full control of PLLC, made all

decisions. Under Mississippi law, would thus not be considered

ltd partner.

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Castigliola - continued

Negligence penalty waived by court Reasonable reliance on CPA

Query: Did the IRS assess a preparer penalty?

http://www.ustaxcourt.gov/ustcinop/opinionviewer.aspx?ID=11178

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Health Care

Indexed Amounts HRA Legislative Relief – QSEHRA President Trump Exec Order on ACA ACA Repeal/Replace Update

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Indexed Amounts for 2016 and 2017

2014 2015 2016 2017§36B and §4980H affordability safe harbor factors

9.5% 9.56% 9.66% 9.69%

§5000A factorfor unaffordable exemption

8.0% 8.05% 8.13% 8.16%

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Rev Proc 2016-24 (4/11/16)

Rev Proc 2016-24 also provides the §36B Applicable Percentage Table for 2017.

§4980H Amounts2015 2016 2017

§4980H(a) penalty – did not offer coverage and at least one FT employee claimed PTC

$2,080 per FT employee

$2,160 per FT employee

$2,260 per FT employee

§4980H(b) penalty – did offercoverage, but either was not minimum value or affordable

$3,120 per FT employee who claimed

PTC

$3,240 per FT employee who claimed

PTC

$3,390 per FT employee who claimed

PTC

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Above amounts are annual. Penalty is prorated for months of violation.

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Qualified Small Employer

Health Reimbursement Arrangement

(QSEHRA)P.L. 114-255(12/13/16)

Small Employer HRA Refresher

Notice 2013-54 – If employer provides reimbursements for employee health plans, then it is considered a plan and must meet “market reforms.” These plans will fail. Employer at risk of $100/day/employee penalty.

IRC §4980D.

https://www.irs.gov/pub/irs-drop/n-13-54.pdf

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IRS Provided Limited Relief

Notice 2015-17 No penalty assessed through June 30,

2015 And relief for 2-percent shareholder-

employee of S corp until IRS issues guidance. IRS has not issued such guidance.

https://www.irs.gov/irb/2015-14_IRB/ar07.html19

HRA Change - New §9831(d)!P.L. 114-255 (12/13/16)

Employers who are not an “applicable large employer” and do not offer group health plan.

No employee contributions to the funding (no salary reduction).

Amount of payments and reimbursements for any year do not exceed $4,950 for single $10,000 for family members of the employee Adjust for inflation

Notice to employees (more later). Benefit – no $100/day/EE penalty + EE exclusion

per Rev Rul 61-146.

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May only exclude employees who …

(i) have not completed 90 days of service; (ii) under age 25; (iii) part-time [Reg. 1.105-11(c)(2)(iii)(C)] or seasonal employees; (iv) are not included in the plan who are included in a unit of

employees covered by an agreement between employee representatives and one or more employers which the Secretary finds to be a collective bargaining agreement, if accident and health benefits were the subject of good faith bargaining between such employee representatives and such employer or employers; and

(v) nonresident aliens and who receive no earned income (within the meaning of section 911(d)(2)) from employer which constitutes income from sources within the US (within meaning of section 861(a)(3)).

[§105(h)(3)(B)]

Employer notice to employees “§9831(d)(4)(A) IN GENERAL.—An employer funding a qualified small

employer health reimbursement arrangement for any year shall, not later than 90 days before the beginning of such year (or, in the case of an employee who is not eligible to participate in the arrangement as of the beginning of such year, the date on which such employee is first so eligible), provide a written notice to each eligible employee which includes the information described in subparagraph (B).

“(B) CONTENTS OF NOTICE.— “(i) A statement of amount which would be such eligible employee’s permitted benefit

under the arrangement for the year. “(ii) A statement that eligible employee should provide information described in clause

(i) to any health insurance exchange to which employee applies for advance payment of the PTC.

“(iii) A statement that if employee is not covered under minimum essential coverage for any month the employee may be subject to tax under §5000A [individual mandate] for such month and reimbursements under the arrangement may be includible in gross income.”.

Purpose – so employee and IRS know Plan coordinates with Premium Tax Credit

Penalty if not done - §6652(o)

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Addition to §106 exclusion:

“(g) QUALIFIED SMALL EMPLOYER HEALTH REIMBURSEMENTARRANGEMENT.—For purposes of this section and section 105, payments or reimbursements from a qualified small employer health reimbursement arrangement (§9831(d)) of an individual for medical care (§213(d)) shall not be treated as paid or reimbursed under employer-provided coverage for medical expenses under an accident or health plan iffor the month in which such medical care is provided the individual does not have minimum essential coverage (within the meaning of §5000A(f)).”

SO, if employee doesn’t have minimum essential coverage –

employer reimbursement is taxable!

W-2 ReportingNew §6051(a)(15) “the total amount of permitted benefit (as defined in §9831(d)(3)(C)) for the year under QSBHRA (as defined in §9831(d)(2)) with respect to the employee.”

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Effective Dates Generally – tyba 12/31/16 “TRANSITION RELIEF—relief under Treasury

Notice 2015–17 shall be treated as applying to any plan year beginning on or before December 31, 2016.” S corp relief continues

https://www.dol.gov/sites/default/files/ebsa/about-ebsa/our-activities/resource-center/faqs/aca-part-35.pdf

Employer who wishes to create a QSEHRA in 2017, has 90 days from 12/13/16 to comply with notice requirement (to avoid the penalty) .

QSEHRA – More Time to Get Notice to Employees for 2017

Notice 2017-20 (2/27/17) Extends time to get initial written notice

to eligible employees from 3/13/17 to “at least 90 days after additional guidance regarding the contents of the QSEHRA notice is issued.”

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Executive OrdersEO 13765 (1/20/17) – Minimizing the Economic Burden of the Patient Protection and Affordable Care Act Pending Repeal.

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https://www.whitehouse.gov/the-press-office/2017/01/2/executive-order-minimizing-economic-burden-patient-protection-and

2/15/17https://www.irs.gov/affordable-care-act/individuals-and-families

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IRS Response to EO (2/15/17)

Will not reject 1040s w/o health coverage information. “However, legislative provisions of the ACA law are still in force until

changed by the Congress, and taxpayers remain required to follow the law and pay what they may owe.”

“Processing silent returns means that taxpayer returns are not systemically rejected by the IRS at the time of filing, allowing the returns to be processed and minimizing burden on taxpayers, including those expecting a refund. When the IRS has questions about a tax return, taxpayers may receive follow-up questions and correspondence at a future date, after the filing process is completed. This is similar to how we handled this in previous years, and this reflects the normal IRS post-filing compliance procedures that we follow. ”

https://www.irs.gov/affordable-care-act/individuals-and-families/individual-shared-responsibility-provision

ACA Repeal/Replace Update H.R. 1628

Passed in House 5/4/17 (217-213) Waiting for Senate action JCT analysis includes:

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Provision Revenue Effect FY 2017-2026 in millions ($)

Repeal medical devise excise tax of 2.3% $19,622Repeal annual fee on branded drugs $38,469Repeal additional Medicare tax of 0.9% for high income

$58,553

Change medical expense deduction threshold from 10% AGI to 5.8% AGI for regular tax and AMT

$125,733

Repeal tanning salon excise tax $144,727Repeal 3.8% Net Investment Income Tax $177,202

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Reminder of ACA Tax Provisions - 1Provision IRC Section

COD income exclusion for certain student loans (effective starting 2009) 108(f)(4)

10% excise tax on indoor tanning services (started July 1) 5000B

Small business health insurance credit [ACA includes later changes such as a requirement starting in 2014 to obtain coverage through the Small Business Health Options Program (SHOP) Marketplace, and that the credit is only available for two consecutive years.]

45R

Expanded dependent coverage exclusion for employer-provided health plans until age 27

105(b)

Codification of economic substance doctrine 66627701(o)

Increase in adoption credit and exclusion increased; refundable credit; temporary

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Credit for Qualifying Therapeutic Discovery Projects (2009 and 2010 only)

48D

Disclosure allowed for certain information to Health and Human Services for the Premium Tax Credit and cost-sharing

6103

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Reminder of ACA Tax Provisions - 2

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Effective 2011W-2 reporting of cost of employer-provided health insurance (postponed for all employers for 2011 and indefinitely for employers who issued less than 250 Forms W-2 in the prior year) [Notice 2010-69, Notice 2012-9, and IRS website]

6051(a)(14)

SIMPLE cafeteria plans allowed for small businesses 125(j)Restricted definition of “medicine” for certain savings arrangements, such as for an Archer MSA

220, 223

Increased tax on distributions from HSA and Archer MSA 223Annual fee on manufacturers and importers for certain prescription drug sales [Form 8947, Report of Branded Prescription Drug Information and Notice 2011-9]

Reg. §51.2(d)

Effective 2012Information reporting for payments of $600 or more made to C corporations [repealed before effective, P.L. 112-9, 2/14/11]

6041

Fee on health plans to fund Patient-Centered Outcomes Research Trust Fund ($1/year, increasing later)

4375

New requirements for §501(c)(3) hospitals 501(c)(3)

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Reminder of ACA Tax Provisions - 3

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Effective 2013Increase in Hospital Insurance tax (additional 0.9%) for high income individuals

3101(b)

New tax of 3.8% on unearned income of high income individuals, estates and trusts (net investment income tax)

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Increase in medical expense deduction threshold to 10% of AGI unless age 65 or older

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Salary reduction contributions to health FSA capped at $2,500 (adjusted for inflation after 2013)

125(i)

Limit on deduction of certain excessive employee remuneration paid by certain health insurance providers

162(m)(6)

§139A, Federal subsidies for prescription drug plans, changed as follows: “Gross income shall not include any special subsidy payment received under section 1860D-22 of the Social Security Act. This section shall not be taken into account for purposes of determining whether any deduction is allowable with respect to any cost taken into account in determining such payment.”

139A

2.3% excise tax on sales of certain medical devices [moratorium for 2016 and 2017 per P.L. 114-113 (12/18/15)]

4191

Reminder of ACA Tax Provisions - 4

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Effective 2014Small business health insurance credit must be offered through SHOP (exchange) 45R(g)(3)

Premium Tax Credit (PTC) available to individuals who obtain coverage on an exchange and meet other eligibility criteria. [Supreme Court holds that individuals in a state without an exchange are eligible for a PTC on the federal exchange. Effect is that individuals in states without an exchange and without coverage must factor in hypothetical PTC to determine if they meet the unaffordability exemption to the individual mandate (King v Burwell, No. 14-114 (6/25/15))]

36B

Individual mandate (penalty) applies if individual and shared responsibility family does not have coverage and does not meet an exemption [Supreme Court found this to be a permissible tax (National Federation of Independent Business, et al v. Sebelius (6/28/12)]

5000A

Employer mandate (penalty) applies if applicable large employer (ALE) does not offer coverage to full-time employees and their dependents up to age 26 (and other provisions). [IRS delays effective date to 2015 and for 2015 provides additional transitional relief. Notice 2013-45 and blog post of 7/2/13 of Assistant Treasury Secretary for Tax Policy Mark J. Mazur.]

4980H

Information reporting by exchanges, insurance providers and ALEs (Form 1095-A, 1095-B and 1095-C, respectively). [IRS make 1095-B and 1095-C reporting optional for 2014.]

36B(f)(3)60556056

Certain types of health coverage reimbursement arrangements (HRA) will fail the “market reforms” exposing the employer to a penalty of $100/day/employee. [Notice 2013-54 and IRS website] [In Notice 2015-17, IRS provided relief through 6/30/15; Congress provided relief through 12/31/16 (P.L. 114-255 (12/13/16))]

4980D

Excise tax on certain health insurance providers Reg. 57.1, et seq. (TD 9643

(11/29/13))

Increase in estimated tax payments for large corporations (assets of $1 billion or more) due in July, August, or September 2014

6655

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Reminder of ACA Tax Provisions - 5

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Effective 2017Increase in medical expense deduction threshold to 10% of AGI for individuals age 65 or older (applicable to other individuals starting in 2013)

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Qualified Small Employer Health Reimbursement Arrangement allowed starting 1/1/17 [added by P.L. 114-255 (12/13/16))]

9831(d)6051(a)(15)

6652(o)106(g)

36B(c)(4)

Effective 2018Nondeductible 40% excise tax on high cost employer-sponsored health coverage (“Cadillac” plans) [postponed to 2020 by P.L. 114-113(12/18/15)]

4980I

Questions to resolve… If made §469 regrouping when first subject to

NIIT, can you (must you) go back to original grouping?

Will it also include repeal of HRA change by PL 114-255 (12/13/16)?

What kind of transitional relief? For example, repeal of exclusion for employer

coverage on non-dependent child … Effective 1/1/17 or when the coverage ends (assuming it

ends)?

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Timing considerations

To avoid ISRP and ESRP for 2017 –need to have coverage Who knows when any repeal will be

effective? Some temp regs expire in 2017 Example – TD 9683 on PTC – 7/24/17

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Property Transactions

§280F Limitations for 2017 Bitcoin Reporting Concerns of IRS

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§280F Limitations for 2017

Rev. Proc. 2017-29 (3/24/17)

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Passenger cars

With bonus depreciation

Without bonus depr

1st tax year $11,160 $3,1602nd tax year $5,100 $5,1003rd tax year $3,050 $3,050Each succeeding year

$1,875 $1,875

Bitcoin Reporting Concerns of IRS

11/16 – IRS files petition to get 2 years of records from Coinbase

ND CA holds there is justification 3/17 – IRS files petition asking Coinbase to state why

it should not comply IRS notes underreporting concerns

Workers paid in bitcoin not reporting 2013 – 2015 – each year, only 800–900 Forms 8949 said

“bitcoin” Based on other data, seems to be too low

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And, there is more than bitcoin

716 virtual currencies per http://coinmarketcap.com/all/views/all/

At 4/29/17

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Market Cap PriceBitcoin $21.5 billion $1,316Ethereum $6.3 billion $69.37Ripple $2 billion $0.05Litecoin $816 million $16.05

http://www.21stcenturytaxation.com/virtual-currency-and-tax.html

Reminder …

Question for organizer and annual planning meeting with clients …

Do you own or use any virtual currency?

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Practice and Procedure PTIN Fee Found Invalid User Fees and Pay.gov IRS Assistance – Make an Appointment LB&I Campaigns Private Debt Collection Launched IRS Dirty Dozen Scam List for 2017 Is it the IRS at Your Door?

PTIN Fee Found Invalid Steele, et al., No. 14-cv-1523-RCL (DC DC,

6/1/17) Class action launched 2016 challenging validity of

PTIN fee in light of Loving. Held –

IRS has authority to require PTIN No authority to charge fee

Fee implies regulatory scheme and can’t regulate individuals who only prepare returns.

No “service or thing of value” provided by IRS Anyone today can get a PTIN – nothing special from IRS No proof that necessary for SSN disclosure purposes.

https://ecf.dcd.uscourts.gov/cgi-bin/show_public_doc?2014cv1523-78

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PTIN Fee – What’s Next

IRS website at 6/2/17 PTIN reg and renewal suspended IRS working with DOJ on how to proceed

Check back at https://www.irs.gov/for-tax-proshttps://www.irs.gov/tax-professionals/ptin-system-down

Refunds? IRS: 710,553 x $33 = $23.4 million! 710,553 x $50 = $35.5 million!!

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User Fees and Pay.gov – Starts June 15

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https://www.irs.gov/uac/newsroom/for-letter-rulings-and-similar-requests-electronic-payment-of-user-fees-starts-june-15-replaces-paying-by-check

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Need IRS Assistance? – Make an Appointment

IRS Special Edition Tax Tip 17-10 In person assistance – you MUST make an appt. First though, check out self-service options, such as

Pub 17, how to pay, how to check refund, etc. Also see Pub 5136, IRS Services Guide

Also has resource tips for preparers.

https://www.irs.gov/uac/newsroom/irs-face-to-face-help-is-now-by-appointmenthttps://www.irs.gov/pub/irs-pdf/p5136.pdf

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LB&I Campaigns

Launched Jan. 2017 “Address compliance and resource challenges.” 13 announced as of April 2017, including

Related party transactions Land developer and completed contract method S corp losses in excess of basis Repatriation 1120-F non-filer

https://www.irs.gov/businesses/large-business-and-international-compliance-campaigns

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Private Debt Collection Launched PL 114-94 (12/4/15); IRC §6306; Pub 4518 4 agencies selected IRS will notify t/p first No enforcement action Payments go to IRS

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https://www.irs.gov/businesses/small-businesses-self-employed/private-debt-collection

IRS Dirty Dozen Scam List for 2017

1. Offshore tax cheating

2. Frivolous tax arguments

3. Abusive tax shelters4. Falsifying income5. Falsely padding

deductions6. Excessive business

credit claims

7. Falsely inflating refund claims

8. Fake charities9. Return preparer

fraud10. Identity theft11. Phone scams12. Phishing schemes

50https://www.irs.gov/uac/newsroom/irs-summarizes-dirty-dozen-list-of-tax-scams-for-2017

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Is it the IRS at Your Door? Audit – letter first + set

appt Collections or CID –

possibly unannounced IRS person will have 2

forms of ID Pocket commission HSPD-12 card

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Miscellaneous

Regulations Issued in 2017 Estate Tax Closing Letter

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Regulations list for 2017

http://www.sjsu.edu/people/annette.nellen/website/2017regs.html

Past list links (2011 – 2016) http://www.sjsu.edu/people/annette.nellen/website/2016regs.html

Estate Tax Closing Letter

Notice 2017-12 (1/6/17) Explains methods available to confirm closing of

estate tax return exam. Account transcript with a transaction code of “421” and

explanation “Closed examination of tax return” can serve as the functional equivalent of an estate tax closing letter in confirming the closing of an examination.”

Not currently available online.https://www.irs.gov/pub/irs-drop/n-17-12.pdf

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California Updates

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New Due Dates for TY 2016+

As a result of the Federal changes in due dates for many types of income tax returns, California has mostly (but not fully) conformed to the Federal law due date changes that went into effect starting for the 2016 tax year.

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California Due Dates: Non-Indiv.Entity Original due date Extended due date

C corp 15th of 4th month 15th of 10th month

S Corp 15th of 3rd month (no change)

15th of 9th month

Exempt Corp 15th of 5th month(no change)

15th of 11th month

Partnerships 15th of 3rd month 15th of 9th month

LLC taxed as corp 15th of 4th month 15th of 10th month

LLC taxed as partnership

15th of 3rd month 15th of 9th month

SMLLC owned by passthrough

15th of 3rd month 15th of 9th month

All other SMLLCs 15th of 4th month 15th of 10th month57

EDD – Mandatory eFiling and ePayments: 2017 & 2018

Beginning 1/1/17, employers with 10+ employees must eFile employment tax returns and wage reports AND must make all payments electronically.

Full eFile and ePay mandate for ALL employers starting on 1/1/18.

http://www.edd.ca.gov/Payroll_Taxes/E-file_and_E-pay_Mandate_for_Employers.htm 58

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EDD – Mandatory eFiling and Payments: 2017 & 2018 (Cont.)

Current penalties for non-compliance with eFile and ePay mandates:

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EDD – Mandatory eFiling and ePayments: 2017 & 2018 (Cont.)

Potential Waiver from eFiling and ePayIn unique situations the EDD may grant a waiver from the eFile and ePay mandates.

If granted, waiver only for one year.

Form DE 1245W Required to Request Waiver

See Rev. & Tax. §§1088(h)(3) and 1110(g)(3)

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EDD – Mandatory eFiling and ePayments: 2017 & 2018 (Cont.)

Potential Waiver from eFiling and ePay

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Appointments Now Accepted at FTB Field Offices for Revivor Applications For those who have a business client that has

been suspended or forfeited that needs to be revived with the FTB, appointments are now available at FTB field offices.

Will take 16 appointments per day. Must call applicable FTB office to schedule an

appointment:

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California Secretary of State – Updated Website: Additional Business Documents Available Online

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Swart Enterprises, Inc. 1/12/17 FTB loses again. On 2/22/17, FTB announces they will not appeal. Iowa Corporation with no physical presence or sales in California,

owns a 0.2% interest in a manager-managed LLC in California.

The court found:1. Swart was merely a passive investor in the LLC.2. Swart had no right to act for the LLC and was not allowed to

participate in management and control.3. When an LLC “checks the box” to be taxed as a partnership that

does not make passive investors such as Swart a general partner. Instead, state law determines legal rights of owners. Also, such election might make the LLC a limited partnership.

4. Swart’s interest was comparable to a limited partner interest.5. An owner’s right to relinquish control over to a manager group is not

necessarily evidence of exercising control over the entity. Here, Swart was not an original investor. It never relinquished control. The court also found this issue irrelevant.

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Other Recent California Updates:

C Corp. Estimated Tax Penalty Calculation

On 4/17/17, FTB acknowledged that the estimate penalty ending calculation date under Rev. & Tax. §19145 for C corps. remained at March 15 (did not change when return due date was changed to April 15). FTB may have miscalculated some penalties.

Contact FTB if you believe the estimated tax penalty was miscalculated (FTB will calculate the penalty to March 15 manually).

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Other Recent California Updates:Revised Due Date on California Withholding Notification to Non-U.S. Partner / Member

Beginning on or after 1/1/2016, the California Tax Withholding Statement (Form 592-B (or equivalent)) for non-U.S. partners / members is now normally due the 15th day of the third month following the tax year (March 15 for CY). Previously is was the 15th of the fourth month (April 15).

Other non-California (but within the U.S.) partners / members must still be sent their 592-B by January 31.

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Other Recent California Updates:Appeal of Lowe/Berkoff (BOE Hearing – Case 571973)

Actor Rob Lowe and wife Sheryl Berkoff sell home in Santa Barbara for approx. $25M in 2005.

TPs reported approx. $10M taxable gain on sale. After exmination, FTB held that taxable gain was

approx. $19M because most of the detailed documentation re: basis was lost due to crash by TPs former accountants back in 2002.

On 9/27/16 BOE held taxable gain at approx. $13M – allowed evidence of detailed summaries by former accountant. Published in Jan. 2017.

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Disclaimer

This information is provided for educational purposes. Many of the topics covered could easily be individual lessons on their own. This update serves as awareness of key developments and the basics of each. It is not intended to answer specific tax questions or provide details of the underlying law noted in each update. Application of any item requires the user to consult the primary authority referenced and related rules, and consider the particular facts at hand.

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